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CIR vs. Philippine Bank of Communications

COMMISSIONER OF INTERNAL REVENUE, PETITIONER, VS. PHILIPPINE BANK OF COMMUNICATIONS, RESPONDENT.

G.R. No. 211348 | 2022-02-23

D E C I S I O N
 
HERNANDO, J.:
 
This petition for review on certiorari[1] challenges the October 7, 2013 Decision[2] of the Court of Tax Appeals (CTA) en banc in CTA EB Case No. 933, and its February 10, 2014 Resolution,[3] ordering petitioner Commissioner of Internal Revenue (CIR) to issue a tax credit certificate (TCC) in the amount of P4,624,554.63, to respondent Philippine Bank of Communications (PBCOM), representing the latter's unutilized creditable withholding tax (CWT) for taxable year 2006.

The facts of the case, as reiterated in the CTA en banc Decision and based on the...